If you hold a New York insurance license, you need to renew your DFS Cybersecurity Certificate of Compliance again in 2020. New York takes the threat of cyber attacks seriously and ITI believes you should too. So, what do you need to do?
Before we talk about 2020, we must address 2019. According to the NYDFS, thousands of licensees did not comply with the 2019 Cybersecurity filing requirement. There are no exceptions or exemptions to the Rule and all licensees must file, even those who are not active in the business, but continue to renew and hold their producer license. If you are not sure if you filed in 2019, you can review your status through the DFS Cybersecurity Portal https://myportal.dfs.ny.gov/web/cybersecurity/. If you did not file in 2019, do it now. You can refer to ITI’s previous blog and the DFS has assistance for you in their Cyber Security Resource Center https://www.dfs.ny.gov/industry_guidance/cybersecurity.
Next, for the majority who did file in 2019, get ready to file again in 2020, between January 1st and April 15th. That gives you a more than a 100 day window to comply with Part 500 of the Financial Services Regulations. You should note that this filing requirement is an annual event and you will need to do it again every year you keep your license. What is different for the renewal is you don’t need to file a “Notice of Exemption” again, unless something about your business has changed. Follow the same DFS Cybersecurity Portal path https://myportal.dfs.ny.gov/web/cybersecurity/ to complete the 2020 filing.
Please remember, we at ITI cannot help you complete your filing and we cannot tell you what exemptions may apply to you. Your questions are best directed to firstname.lastname@example.org, the Department of Financial Services Cyber Regulatiosn Support Team.
We do hope this message helps you understand this important program a bit better.
Life insurance producers in New York have a newly revised Regulation 187 to comply with effective August 1st, 2019. The Regulation “does not require the completion of specific training classes”, however companies are responsible for ensuring “that producers are adequately trained with respect to their insurer’s policies to make recommendations”.
Active producers, by now, have heard from their carriers and almost certainly received training that meets the new NY-DFS standards. Inactive producers are not necessarily required to complete a training program prior to the August 1st deadline, however, the standard will need to be met if they plan to work with any existing or prospective customer.
A summary of the new Regulation has been published by the New York Department of Financial Services at https://www.dfs.ny.gov/docs/insurance/r_finala/2018/rf187a1summary.pdf. Additional information is also available through the DFS.NY.GOV website.
Insurance Training Institute often discusses new and updated New York State Regulations in our continuing education courses, but individual insurance companies are free to require specific or proprietary training from their producers. It is our belief that producers are best served by those specific programs.
ITI looks forward to seeing you again soon to meet your NY-DFS continuing education requirements.
Many of your received an end of the year message from our Department of Financial Services about compliance with the new Cybersecurity Regulation. New York State is serious about cyber security and this is one of their many efforts to protect you, your clients and our financial services industry. We at ITI support this program. However, to many individuals compliance is still a bit confusing.
In a nutshell, the DFS wants each licensee to confirm, each and every year, that they are taking steps to prevent bad actors from hacking into our computer networks. Big entities, including brokerage houses, insurance carriers and large agencies must have sophisticated systems and regularly test their defenses using a “third party” to ensure system integrity. Small agencies and independent individual licensees are exempt from many of these requirements, but they have compliance requirements. Every licensee must still have a written “cybersecurity program” in place.
Your cybersecurity program will describe in writing the steps you need to take if you find that your computer has been subject to a “Cybersecurity Event”.
A Cybersecurity Event is “any act or attempt, successful or unsuccessful, to gain unauthorized access to, disrupt or misuse and Information System or information System or information stored on such Information System.
Remember, this is not your run of the mill problem with your computer, restarting your computer is not going to be enough and at that point it is too late to simply install an anti-virus program. You need to do more! You will need to contact the companies you have access to and let them know your login credentials have been compromised. Your companies should help you from there. You also will need to notify the DFS. Keep in mind this is where those bad actors use your login and password to get into the bigger systems.
So, where do you start? If you are uncertain, your first step might be with your carriers, especially if you have an agent contract with them. If you are truly an independent, the DFS has lots information to help. Remember, this is a good program and will only take you a short time to complete each year.
Step 1. Follow the link from your email from the DFS: https://www.dfs.ny.gov/system/files/documents/2019/01/cyber_compliance_filing_instructions.pdf
Step 2. Click the link to the Cybersecurty Portal and enter your email address and password. If you do not remember Your password, there is a “forgot password” link to get you moving forward.
Step 3. Follow the prompts through, it is very straight forward.
Step 4. Remember, there is a second step. You need to complete the “Compliance” step also. That is the middle tab.
We at ITI cannot help you answer the questions and we cannot tell you what exemptions may apply to you, but we hope this message helps you understand this important program a bit better.
Hello my friends.
Over the last 22 years we at ITI have worked to bring you education classes and news from our insurance industry to help you to keep up to date. Adding this BLOG page to our website brings that one-step further. Licensing issues are important and we will do our best to bring you information about changes that impact your business. The most recent updates comes from the Department of Financial Services Licensing Bureau.
On Tuesday, December 11th, the NYSDFS released a memo announcing changes to Insurance Law Sections 2103 and 2014, licensing for Property Casualty Agents and Brokers. This new change (S7634-A/A9527-A) allows individuals to complete their pre-licensing training online, instead of in a classroom setting. The new Law took effect immediately. We agree with the sponsors of this legislation that licensing will now be much easier to obtain for people in rural areas around New York.
Subject: New York State Department of Financial Services Insurance Licensing Education – PC prelicensing course
On Friday, December 7, New York governor Andrew Cuomo signed into law changes to Sections 2103 and 2104 that address prelicensing education requirements.
Effective immediately, those seeking to obtain a Property Casualty license must complete an approved course requiring a minimum of 90 hours of classroom instruction or the equivalent in correspondence work, or a course offered over the internet. Those seeking a Personal Lines license must complete an approved course requiring a minimum of 40 hours of classroom instruction or the equivalent in correspondence work, or a course offered over the internet.
All courses must be approved by this Department before they can be offered to the public. We are developing criteria to guide you in the development of online courses and will publish them in the very near future. You must submit course approval applications to obtain approval.
Please email any questions or concerns to email@example.com. We are eager to work with you to make these courses available as soon as possible.
New York State Department of Financial Services
One Commerce Plaza, Albany, NY 12257
The other significant new law changes the date for all corporate license renewals to June 30th of “Odd Numbered Years”. This law takes effect July 1, 2019. This change will certainly help corporations with license management.
We should note here that another change for corporate sub-licensees was made law in 2017 that enables business entities to renew their licenses as long as the sub-licensees are current with their licenses. Sub-licensees no longer need to complete their education to match their corporate renewal dates.
Thank you for reading and feel free to write a note and let me know your thoughts too.